ML20070J778

Requests Approval of Encl Proposed Change to QA Program Description,Revising Section 1B.11, Test Control

ML20070J778
Person / Time
Site:	Calvert Cliffs
Issue date:	03/07/1991
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9103180128
Download: ML20070J778 (4)

Text

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ABALTIMORE GAS AND ELECTRIC CHARLES CENTER e P.O. BOX 1475

• BALTIMORE. MARYLAND 21203 1475 Gromot C CRttL  :

Viet Pas sic, tait

%Catam (ast eps ooo eso.. ass March 7,1991 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTl!NTION: Document Control Desk SUBJECI Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50 317 & 50-318 Prooosed Change to Ouality Assurance Program Description Gentlemen: I in accordance with 10 CFR 50.54(a)(3), Baltimore Gas and Electric (BG&E) Company hereby requests approval of a proposed change to the Quality Assurance Program for Calvert Cliffs Unit Nos.1 & 2. The propcsed change would revisc Section 1B.11. " Test Control" of the Quality Assurance Policy. We propose to change the program as reficcted in the description shown on the attachment. Nuclear Regulatory Commission approvalis required prior to implementation of this change since the change constitutes a reduction in the quality assurance 3rogram commitments as previously accepted. This portion of the program is also described in tic Updated Final Safety Analysis Report (UFSAR), Chapter 1, Appendix B, Section 1B.11.

• Test Control." The UFSAR description is updated annually in accordance with 10 CFR 50.71.

The proposed change will relieve the Plant Oncrations and Safety Review Committee (POSRC) and the Plant General Manager of the burden at resiewing and approving the results of safety related (SR) and certain non-safety related (NSR) tests which are completed with satisfactory results. The current Quality Assurance Policy regarding Test Control states in part:

"With the exception of testing performed as part of receipt inspection and completed surveillance tests performed without malfunctions or out of specification data, results of tests are reviewed and evaluated by the POSRC and accepted and approved by the Plant General Manager."

• This statement provides an exception to the requirement for POSRC review of test results and subsequent Plant General Manager approval. This exception is provided since the knowledgeable technical personnel and the cognizant management approval authority have previously revicu:d the applicabic procedures, including the acceptance criteria, and determined them to be acceptable. If l

the results are not acceptable or there were malfunctions during the test, then the POSRC should '

review the results and determine their impact on the safety of the ;)lant,if any. However,if the test i was performed satisfactorily, there is no benclit gained by additiona , review of acceptable test results.

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l Docun,ent Control Desk March 7,1991 Page 2 Currently, this exception is limited to surveillance tests only However, many other categories of test procedures are also prepared and reviewed by knowledgeable technical personnel and approved by cognizant management approval authority. These reviews also provide no added safety benefit if there are no malfunctions and the acceptance criteria are met. Therefore, BG&E proposes to change the above wording to read as follows:

• Results of completed tests on SR and designated NSR structures, systems and components (per 0 List) that identify a malfunction or were out of sperincaticen are reviewed and evaluated by the POSRC and accepted and rpproved by tha Plant General Manager,"

This change to the quality assurance program will ensure POSRC evaluation and Plant General Manager approval of test results which may have an adverse effect on nuclear safety, but will free them of the unnecessary administrative burden of evaluating and approving satisfr,ctory test results.

More of the POSRC members' time can thus be devoted to evaluation of sarcty concerns.

Operation in accordance with the proposed change would continue to satisfy Appendix B of 10 CFR Part 50. Criterion XI requires, in part, that test results be evaluated to assure that test requirements ham beca satirfled. This evaluation has been, and would continue to be, performed by a qualified responsible individual or group. If the test results are not satisfadory due to rnalfunction or being outside the specified acceptance criteria, then additional review would be required by the POSRC and the Plant General Manager.

Considering the above information, we conclude that the proposed change to our Quality Assurance Program will maintain the effectivencas of the test results review process. Should you have any questions regarding this matter, we will be pleased to discuss them witi you.

Very truly yours,

/, ; .

GCC/ ERG /crg/dtm

Attachment:

Execrpt from Section 1D.11 of the QA Policy cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. O. Mcdonald, Jr., NRC T, T. Martin, NRC L E. Nicholson. NRC R. I. McLean, DNR j

J. II. Walter, PSC l

_ _ _ - ~ _ _ . _ _ , . _ . _ _ _ _ . - _ . _ . _ , - . , _ _ _ __,

A1TACilMENT 1 QUALITY ASSURANCE POLICY E8EU I DI2 Revision 24 18.11 TEST CONTROL To demonstrate the ability of SR and designated NSR structures, systems, and components to function as desi6 ned, they are subjected to a program of surveillance and operational testing. Procedures specify the syst. eat!.c development, review, approval, and conduct of teste s.d review of tese results. Conditions such as failures, r,aifunctions, deficiencies, deviations, and non conformances discovered during cesting are documented and evatusted.

Whenever testing is required to demonstrate that SR and designed NSR material, parts, components, or systems will perform satisf actorily in service, a test program is established and procedures are used that have been written and approved in accordance with basic requirements.

1 Nuclear Engineering Department, and CCNPPD conduct tests to verify that plant behavior conforms to design criteria, ensure that failure and substandard performance are identified and controlled, and demonstrate satisfactory performance after plant modification and maintenance activities.

Vritten test precedures are developed, reviewed, and approved before testing la performed. They specify instructions for testing, methods of test, test equipment, and instrumentation; and for the following as applicable:

1. Adequate and appropriate equipment.

2. Preparation, condition, and completeness of item to be tested.

3. Suitable and controlled environmental conditions.

4. Mandatory inspection hold. points for witness by B06E inspection or authorized inspector personnel.

5. Provision for data collection and storage.

l 6. Acceptance and rejection criteria.

7. Methods of documenting or recording test data and results.

8. Provision for ensuring that test prerequisites have been met.

Test results are documented aad evaluated; they are accepted or rejected by a qualified, responsible individual or group.

4 3 ggg IV.ith the exception of testing performed as part of leceipt inspection and

,,qf 'ecapleted surveillance tests performed without malfunctions or out of specification data, results of tests are reviewed and evaluated _by the

_POSRC and accepted and approved by the Plant General Manager. J Test records are kept in sufficient detail to make possible an evaluation of test results and to show how individual tests demonstrate that SR and designated NSR structures, systems, and components and the plant as a unit can operate safely and as designed. SR and designated NSR test records are retained as plant history records.

Page 36 of 60

. . ATTACllMl!NT 1

- Page 2 0f 2 Delete the indicated information in the QA Policy, Section 10.11, page 36, and replace it with the following insert:

'Results c.f completed teste on SR and designated NSR structures, systems and cornpone its (per Q List) that identii3 a malfunction of were out of specification are reviewed cad esaluated by the POsRC and accepted and approved by the Plant General Man 6ger.

Note to Reviewers: The UFSAR descri tion will be updated by Rev.11 to reflect the current QA Foi (Rev. 24).

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